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0ft EAIA Unrted States 1"\~~~i~~ mental Protection Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish : Facility Phone Number Facility Contact: 3/19/2024 Toxic Substance Control Act Renovation Repair and Paint (RRP) and 1018 notification Fowler Property Management 1537 Singelton Blvd Dallas TX 75212 Dallas (972) 460-6654 Meagen Johnson I I DFWmamager@Fowlerpropertymgmt.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A N/A N/A 531311 6531 Personnel participating in inspection: Angela Hays EPA Region 6 Stan Lancaster EPA Region 6 Meagen Johnson Fowler Property Management Inspector Inspector Manager EPA Lead Inspector Signature/Date ANGE LA HAys Digitally signed by ANGELA HAYS Date: 2024.05.09 09:01 :50 -05'00' Angela Hays/ Date Supervisor Signature/Date H STUCKEY Digitally signed by H STUCKEY Date: 2024.0S.09 10:26:32 -05'00" Troy Stuckey/ Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I INTRODUCTION PURPOSE OF THE INSPECTION FACILITY DESCRIPTION Section II OBSERVATIONS Fowler Property Management Inspection 03/19/2024 The inspection checklist (Appendix 2) was completed during the inspection. How RRP work is performed was unknown by management. Follow up information was requested. The inspection concluded with a brief explanation of the areas of as compliance requirements and a recap of information requested following the inspection. Section Ill - AREAS OF CONCERN No areas of concern were identified at the time of inspection. Additional information requested to demonstrate RRP compliance . Section IV - FOLLOW UP 1) Number of pre-1978 properties managed by Fowler Property Management 2) Description of how RRP work is managed 3) Firm Certification number 4) Name, contact information, and training of contractors Section V- LIST OF APPENDICES Appendix 1- NOi Appendix 2 - Inspection Checklist 3 Fowler Property Management Inspection 03/19/2024 Appendix 1 Notice of Inspection 4 ~ E PA t t.. I ~r.;;r,;.: ' 1.uonm1~11t~1 Plut~c: it,rt United State5 ENVIRONJVlENTAi. PROTECTION AGENCY Washington, DC 20460 ---- - - - - - - - - - - -- - --------' Notice of Inspection Office of Enforcement and Compliance Assurance C - - -- - 1. lnvesi.igation Identification 3 . Facility Name lDate \11spectio11 Number ,13 -Jo/-24 1 1 o?_ ~ nspector's Address Daily Seq .Number 11 cf<_ I hwl.e.r /4/J~rb I 4. Facility Address I J11&nrl/_..:nt?n, ~ (/ i /Lo/ B-111 sr I va/Lcc5 T~ 7SZD/ 1537 ~~/-/?'YJ8///I) I tw,~ s u I For Internal EPA Use. Copies may be provided to the recipient as acknowledgment of this nqtice. - - - Reason for Inspection 1 ,LJndei the authority of Section 11 of the Toxic Substances Control Act I For the purpose of inspecting (including taki ng samples, photographs, statements and other inspection activities) an I establishment, facillty or other premises in which chemical substances or mixtures, articles containing same are : manufactured, processed, stored or held before or aft er their distribution in commerce (including records, files, papers, , ~~ processes, control and facilities) and any conveyances being used to transport chemical substance, mixtures or articles I containing same in connection with their distribution in commerce (including records, files, papers, processes, controls and facilities) bearing on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles, within, or associated with, such premise or conveyance have been complied wi th. n In addition, this inspection extends to (check appropriate blocks): O A. Financial Data 0 D. Personnel Data LJ B. Sales Data DE.Research Data D C. Pricing Data IThe nature and extent of inspection of such data specified in A through E above is as follows: Iinspector's Signature !Name Name ~~~~~~ ~il !T-itl_e_:===::::':::1,::::::::"::yt={/!4=~=!=1==1"'=1=-=r==-~~1-~:-_,e~J::el.:::Q:::(::::=- r J ,~ rPl\ Fe.rm 7710-3 (Hev. .!/16) If ~av.e Fo.rrn I J Da1_e~ - ' 9 l lnsp,,cto r Copy 1-r.,,11ity : ,,py Fowler Property Management Inspection 03/19/2024 Appendix 2 Inspection Checklist 5 ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Com an Name Address Contact Name Contact Tele hone Contact Email EPA Firm Certification Number Facility/operator provided copy ofentry document Copy of Lead Base Paint Pamphlet rovided Y - N - NIA Comments 'I y /ti The items identified in this inspection have the potential to incur civil penalties in the amount identified. Your firm has . .90 days in which to submit proof that the items identified have been corrected. These deficiencies are ofa serious nature and if left uncorrected could result in formal enforcement action. Your response should be submitted to: l~ ~lv rntu;:; f,oferff2 ~ frL- / 978'- 7>a~ 01Jsr7 rf,C/' JJ',t> :Jyjf'.#1 II%/ I J c/;e1/1twtcl lkmt_J.ef (Mwi ~.elld1m , Llt>'S~ltt1~I~ . Copy of inspection checklist and on-site report sent.t@ ~ &b/.t-t.arid-n f?vtnbtr - ~r5 c/J , (!);;tlt. , ~4,,- fMftadtfS _- R _'(}, f Print Name: W ~ l/" Date _ _ _ ~ S (Ju/6 l 1n ~on Email: - - - - - - - - - - - - Page 1 of 6 Facility/Company Name: _f_-p_..w....l..l..'._f___,./J;....,_11~_.,._FJL/1--...?l.__1__...r...n..._._~e.m........u......t....f.._ _ _ _ __ r ~/ --er ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION # Ree Ref Question I 40 CFR &745.87(c) Did the company permit entry for inspection? Comments 2 40 CFR 745.87(c) Did the company provide requi::sted information and/or records during or after the inspection? Comments 'fat.II/../ MI II l'ol/11w otJ /,1/ N/2_ /I l>M ,,,..,,Atff-5 3 40 CFR 745.87(c) Is this company a licensed t eal estate brokerage firm? If so, provide state licensing number in comments. Comm,ents 4 40 CFR 745.87(c) Does this company manage target housing? Comments s 40 CFR 745.87(c) How many target housing properties does this company manage? Comments Htllv1t w1U -tolf~,., .,,..,, ,. ,I,'nt-o 6 40 CFR &745.87(c) Are children under the age of 6 ve'ars living in any of these properties? Comments 7 40 CFR 745.87(c) Are pregnant women living in these properties? Comments /1r,l.l1,'11fJ.1rl 8 40 CFR 745.87(c) Has re110vation/repair/painting work been performed on these properties? Comments l-.tt~,l /t, IA I I/( !=dllow uA1J w I 1t1k> 9 40 CFR 745.87(c) Which properties had RRP work t:krformed and when? See List Comments ,= 1')1(/"I,\ 1,,./J 10 40 C.F.R. Did the renovator orlproperty manager provide the owner ofthe unit with 745.84(a)( 1) the EPA-approved lead hazard information pamphlet? Comments Fvtl-,, ,l wl) 11 40 C.F.R. Did the renovator or property manager provide the adult occupant ofthe 745.84(a)(2) unit (if not the owner) with the EPA-approved lead hazard information pamphlet? Comments ,r(ll/(IW ,.,.) 12 40 C.F.R. In Common Areas: did the renovator or property manager provide the 745.84(b)(l) owner ofthe multi-family housing with the EPA-approved lead hazard infonnation/parnphlet or to post informational signs? Comments lo/{(lt.) ,,,,,,-; 13 40 C.F.R. In Common Areas, did the renovator or property manager notify in 745.84(b)(2) writing, or ensure written notification of, each unit of the multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? Comments ~~flow ,,J) 14 40 C.F.R. In renovation in Child-Occupied Facilities, did the renovator or property 745.84(c)(l)(i) manager provide the owner of the building in which the child-occupied facility is located with the EPA-approved lead hazard information pamphlet? Comments Z:"/low UA!J Y-N-N/A V I ( >I V V, Page 2 of6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 15 40 C.F.R. 745.84(c)(l)(ii) ln renovation in Child-Occupied Facility, did the renovator or property manager provide an adult representative of the child-occupied facility with the pamphlet, if the owner is not the operator ofthe child-occupied facility? Comments Hllm- ,..,, 1 16 40 C.F.R. In renovation in a Child-Occupied Facility did the renovator or property 745.84(c)(2) manager provide the parents and/or guardians ofchildren using the child- occupied facility with the pamphlet and information describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the general nature and locations of the renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians ofthe children frequenting the child-occupied facility, and accompanied by a posted copy ofthe pamphlet or information on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? Comments h:>/low ,.p 17 40 C.F.R. 745.85 For all renovat'ions, did the renovator or property management firm post (1). signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to prepare, to the extent practicable, signs in the primary language of the occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post-renovation cleaning verification have been completed? Comments loll,,, ,;? 18 40 CFR Did the firm establish and maintain records and make those records 745.84(a)( I)(i) available during the inspection? Comments HJ//41,.1 ,.AP 19 40 CFR Did the firm receive written acknowledgement from the owner for receipt 745.84(a)( I)(i) ofa lead education pamphlet? Comments J:"111/aw v-tl 20 40 CFR Did the firm receive written acknowledgement from an adult occupant, 745.84(a)(2)(i) of/for a lead education pamphlet? Comments ,, 21 40 C.F.R. Did the firm provide the adult occupant ofthe unit (if not the owner) with 745.84(a)(2) the EPA-aooroved lead hazard information pamphlet? Comments J, 22 40 C.F.R. 745.84(b)(l) Did the renovator provide the owner of the multi-family housing with the EPA~approved lead hazard information/pamphlet or to post informational signs? Comments I( Page 3 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 23 40 C.F.R. Did the renovator notify in writing, or ensure written notification of, each 745.84(b)(2) unit ofthe multi-family housing and make the pamphlet available upon request prior to the start of the renovation, or to post informational signs? Comments I f 24 40 C.F.R. Did the renovator provide the owner ofthe building in which the child- 745.84(c)( I )(1) occupied facility is located with the EPA-approved lead hazard information pamohlet? Comments /1 25 40 C.F.R. Did the renovator or owner provide an adult representative ofthe child- 745.84(c)(l)(il) Comments ,, occupied facility with the pamphlet, if the owner is not the operator ofthe child-occupied facilitv? 26 40 C.F.R. Did the renovator or owner provide the parents and/or guardians of 745.84(c)(2) children using the child-occupied facility with the pamphlet and information describing the general nature and locations of the renovation and the anticipated completion date, by mailing or hand-delivering the pamphlet and renovation information, or by posting informational signs describing the general nature and locations ofthe renovation and the anticipated completion date, posted in areas where they can be seen by parents or guardians of the children frequenting the child-occupied facility, and accompanied by a posted copy of the pamphlet or information on how interested parents or guardians can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to the parents or guardians? Comments JI 27 40 C.F.R. 745.85 (I) Did the renovator or property management firms post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to prepare, to the extent practicable, signs in the primary language of the occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post- renovation cleaning verification have been completed? Comments I I 28 40 C.F.R. During the renovation did the renovator obtain, from the owner, a written 745.84(a)( I) acknowledgment that the owner has received the pamphlet, pursuant to 40 Comments ,, C.F.R. 745.84(a)(1)(i) or failure to obtain a certificate of mailing at least 7 days prior to the renovation? 29 40 C.F.R. During the renovation did the renovator obtain, from the adult occupant, a 745.84(a)(2) written acknowledgment that the adult occupant has received the Comments pamphlet, pursuant to 40 C.F.R. 745.84(a)(2)(i) or failure to obtain a ,, certificate of mailinS! at least 7 days prior to the renovation? Page4of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ft 0 U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION 30 40 C.F.R. 745.84(b)(I )(i) During the renovation in Common Areas, did the renovator obtain, from the owner, a written acknowledgment that the owner had rece1ved the pamphlet, or that infonnation signs had been posted, or they had obtained 40 C.F.R. 745.84(b)(l) a certificate ofmailing at least 7 days prior to the renovation? Comments ti 31 40 C.F.R. During the renovation in Common Areas, did the renovator prepare, sign, 745.84(b)(3) and date a statement describing the steps performed to notify all occupants of the intended renovation activities and offer to provide the Comments pamphlet? ,, 32 40 C.F.R. During the renovation in Common Areas, did the renovator notify, in 745.84(b)(4) writing, the owners and occupants ofthe scope, locations or expected starting and ending dates of the planned renovation activities, before the renovator initiated work beyond that which was described in the original notice? Comments If 33 40 C.F.R. During renovation in a Child-Occupied Facility, did the renovator obtain, 745.84(c)(l)(z) from the owner of the building, a written acknowledgment that the owner had received the pamphlet, or obtained a certificate of mailing at least 7 days prior to beginning the renovation? Comments (I 34 40 C.F.R. 745.84(c)(l )(ii) During renovation in Child-Occupied Facility, did the renovator obtain from an adult representative of the child-occupied facility, if the operator ofthe child-occupied facility is not the owner of the building, a written acknowledgment that the operator had received the pamphlet, or obtained a certificate of mailing at least 7 days prior to bei!innini! the renovation? Comments }( 35 40 C.F.R. 745.84(c)(3) During renovation in Child-Occupied Facility, did the renovator prepare, sign and date a statement describing the steps performed to notify all parents and guardians ofthe intended renovation activities and to provide the pamphlet? Comments JI 36 40 C.F.R. 745.84(d)(l) During all renovations, did the renovator include a statement recording the owner or occupant's name and acknowledgement of receipt ofthe pamphlet prior to the start of the renovation, the address of the unit undergoing renovation, the signature ofthe owner or occupant as aoolicable, and the date ofsignature? Comments JI 37 40 C.F.R. 745.84(d)(2) and (3) During all renovations, did the renovator provide written acknowledgment of receipt ofthe pamphlet on either a separate sheet or as part of any written contract or service agreement for the renovation, and written in the same language as the text of the contract or agreement or lease or pamphlet? Page 5 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ I ft U.S. EPA Lead Renovation/Repair/Painting Compliance Checklist - Property Management US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202 TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Comments 38 40 C.F.R. 745.86 During all Renovations, did the renovator or property manager retain all records necessary to demonstrate compliance with the residential property renovation for a period of 3 years following completion of the renovation activities? Comments JI 39 40 C.F.R. 745.225 During all Renovations, did the renovator, or property manager (i) implement a program to maintain and make available to EPA upon request, records for a oeriod of 3 vears and 6 months? Comments ,, 40 40 C.F.R 745.225, In Target Housing and Child-occupied Facilities, did the owner, 745.226, 745.227, renovator, or property manager establish, maintain, provide, copy, or pennit access to records or reports? 40 C.F.R. 745.235 (b) Comments /I Target Housing Major= one or more occupants under age 6 and/or pregnant woman Significant= no information about age of the youngest occupant, or one or more occupants between ages of 6 and 17 Minor= no occupants under age 18 Child Occupied Facility Major= one or more occupants under age 6 (by definition, a child-occupied facility is regularly visited by one or more children under 6) Minor= renovation activities were completed during a period when children did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children are not returning after the break). Page 6 of 6 Facility/Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __